Report on animal-human hybrid research is ethically and politically regressive
Last Friday (22 July 2011), the Academy of Medical Sciences (AMS) – an association of scientists from industry, academia and government – released a report on experimentation involving the insertion of human material into nonhuman animals (‘Animals Containing Human Material’ [ACHM]). Media coverage interpreted the report as calling for ‘tighter regulation of animal tests’. However, the report’s recommendations are unlikely to make any practical difference to the current practice of weak regulation. On the contrary, by reinforcing established prejudices and behaviours, the report tends to promote both an expansion in animal experimentation and the persistence of this practice.
False assurances on animal welfare
Although it is presented as a ‘study of the scientific, social, ethical, safety and regulatory aspects of research involving animals, and non-human embryos, containing human material’, the language of the report reveals that it also has a significant political element and purpose.
It is seriously misleading for the report to assert that inserting human cells, tissue and genetic information into non-human animals and then experimenting on them, can in any way be consistent with ‘protecting their welfare’. On the contrary, these are actions that deliberately and knowingly endanger the welfare of these individuals through, for example, causing them to suffer painful and distressing diseases such as migraine, anxiety disorders, osteoporosis, diabetes, heart disease or cancer. In a domestic setting, such cruel treatment would be a criminal act.
The AMS decided to limit the scope of the report’s ethical analysis; they make the assumption that harmful and potentially harmful uses of non-human animals are generally morally justified. Therefore the report fails to justify why it is morally unacceptable to inflict pain, suffering and distress on living people but morally acceptable in the case of non-human animals.
This omission is an example of Lukes’ famous 2nd dimension of power, where social questions that might challenge powerful interest groups and the institutionalised social practices that they support are simply not addressed. As a consequence, in dealing with ethical issues, the report rejects analysis and reason in favour of a dogmatic approach rooted in ‘religious and ethnic traditions that draw on an array of sources such as canonical texts, authoritative readings, overlapping (even contradictory platitudes), community norms’ (Vance, 1992: 1718).
The report also misrepresents the previous ethics reports which it cites as a justification for its approach to ethical issues. For example, while the Nuffield Council on Bioethics report concluded that animal experiments can be morally acceptable, it cited major conditions and qualifications:
- ‘The involvement of animals in research cannot be justified simply by the fact that animals are used or abused in other ways…’
- ‘Genuine willingness is also required to test and, where necessary, revise one’s own moral framework.’
- ‘For moral justification of animal research… the question of why alternatives are not available and what is required to make them available must also be asked.’
Far from following in the footsteps of the Nuffield report, the approach taken by the ACHM report directly contradicts these recommendations. This is disappointing as the institutional members of the Nuffield Council (e.g. Wellcome Trust and the Medical Research Council) are also partners of the AMS. As is often the case, they fail to honour their more reflective ethical pronouncements in their lobbying and policy activities.
Maintaining weak regulation
The report misrepresents the way the regulatory framework is supposed to work and its ethical implications, possibly due to the lack of public policy expertise on both the Working Group and the Review Group. Thus, in the press release announcing the report, chairman Professor Bobrow states: ‘The very great majority of [possible ACHM] experiments present no issues beyond the general use of animals in research and these should proceed under current regulation; a limited number of experiments should be permissible subject to scrutiny by the expert body we recommend…’ (emphasis added).
In fact, the Animals (Scientific Procedures) Act 1986 and associated Guidance state that programmes of potentially painful animal experiments can only proceed if they pass a cost-benefit test. However the working group appears to contradict its own descriptions of a ‘strict’ regulatory system by assuming that animal experimentation proposals are/should be automatically approved rather than subject to independent cost-benefit analysis. This common assumption in pro-animal research statements reveals how the ‘regulatory’ system actually operates in practice – animal experimentation proposals are generally rubber-stamped rather than independently assessed. In practice, the law and regulations mainly serve to give the impression of strict regulation, and hence conceal and enshrine the real lack of consideration for animal welfare.
On the one hand, this call for automatic approval of animal experiments reinforces the prejudices about human moral supremacy and the moral status of nonhuman animals that are implicit in such a cavalier approach to animal research. But, of more practical consequence, the report’s lack of consideration for animal welfare further weakens scientists’ motivation to meet the ethical imperative to work towards a world where nonhuman animals are not subject to pain, distress and death in biomedical research (again, a Nuffield recommendation).
Media coverage claiming that the report calls for tighter regulation of animal tests arises from the preceding quote from Professor Bobrow. In the context of the need for a rapid response to the report’s publication, such an interpretation is understandable. However, a closer reading of the report – with the benefit of relevant policy expertise – shows this to be dubious.
In the context of an assumption that such proposals will be authorised, the proposed additional levels of scrutiny add little more to current processes whereby the Animal Procedures Committee already considers: ‘applications of any kind raising novel or contentious issues, or giving rise to serious societal concerns’. Apart from providing some definition for this category, it is hard to see how the ACHM report actually adds to the current regime (or intends to for that matter). It raises the question of whether the report is in some respects a PR exercise: falsely reassuring the public that animal experimentation is strictly regulated in order to prevent that very situation from occurring.